Associate Professor Zephyr Teachout was cited in Justice John Paul Stevens' dissent following the January 21 Supreme Court decision in Citizens United v. Federal Election Commission. The Court's ruling forbids the government from banning political spending by corporations in candidate elections.

Stevens' dissent argues that, by allowing corporate money to influence elections, the country's democratic traditions are at risk of corruption. He specifically questions the possibility of election spending by foreign corporations: "The notion that Congress might lack the authority to distinguish foreigners from citizens in the regulation of electioneering would certainly have surprised the Framers," Stevens said.

Teachout's article, "The Anti-Corruption Principle," 94 Cornell L. Rev. 341 (2009), is cited to support Stevens' claim—that the Framers' "obsession with foreign influence derived from a fear that foreign powers and individuals had no basic investment in the well-being of the country."

Justice Stevens was joined in his dissent by Justices Breyer, Ginsburg, and Sotomayor.